The above document pulls the whole New Narrative story together. The first page is effectively a one-pager that sketches out how:
- The issue can be defined in a way that makes an easily understandable, real-world concern (theoretical as it may be) the narrative driver of the amendments. That concern could (plausibly) also have been the basis of the FCRA Criteria, but ‘addressing collusion risk’ is in Congressional territory — not some technical budgeting matter.
- The solution is simply requiring some additional commonsense due diligence that honest applicants shouldn’t find difficult. Naturally, the FCRA Criteria should be revised to conform the new WIFIA law. Who can argue with any of that?
- There are also opportunities — add a useful economic amendment or two to the proposed language for stakeholders, and importantly make the Criteria revision process a venue for CWIFP and OMB ‘rapprochement’.